AML & Counter-Terrorist Financing Policy

1. Our Commitment

lockt International is committed to preventing the use of its platform for money laundering, terrorist financing, sanctions evasion, or other financial crime. We apply a risk-based AML/CTF programme informed by applicable law in the jurisdictions in which we operate and by international standards, including the Financial Action Task Force (FATF) Recommendations. This programme applies in addition to, not instead of, the AML obligations of the banks, payment processors, and other regulated financial institutions we partner with to hold and move funds.

2. Who This Policy Applies To

This Policy applies to every user who registers for a lockt account — exporters, importers, farmers/producers, freight forwarders — and to any individual who funds escrow, receives escrow, applies for or provides trade finance, or otherwise moves money through the Service. It also governs how lockt personnel and contractors must handle compliance matters internally.

3. Customer Due Diligence (KYC)

Before you may fund or receive escrow, list a commodity, or access trade finance, we require you to complete identity verification ("KYC"), consisting at minimum of:

• A valid government-issued identity document for the individual(s) registering the account and, where applicable, for beneficial owners and authorised signatories;
• Proof of business registration/incorporation for the entity you represent;
• A valid tax identification or PIN certificate;
• A selfie or other biometric check, used to confirm the person registering matches the identity document presented; and
• Any further information reasonably required to understand your business, the commodities you intend to trade, your expected trading volume, and the source of the funds you intend to use.

Submitted documents are treated as a fixed compliance record — once submitted, they cannot be self-service replaced through the Platform, including after a rejected submission, in order to preserve a clean audit trail. To correct or update a document, contact support@lockt.international. Submitting a forged, stolen, expired, or materially misleading document is a serious breach of this Policy and our Terms, and may be reported to law enforcement.

We may decline to open an account, may approve an account with restricted functionality, or may require further information before releasing that restriction, entirely at our discretion.

4. Enhanced Due Diligence & High-Risk Customers

We apply enhanced due diligence — which may include verifying additional documentation, confirming source of funds or source of wealth, obtaining senior compliance sign-off, or limiting transaction size — to customers we assess as higher risk, including where a customer:

• Is, or is closely associated with, a Politically Exposed Person (PEP);
• Operates in a jurisdiction assessed by FATF or an equivalent body as high-risk or subject to increased monitoring;
• Trades in a commodity category with an elevated risk of misuse (for example, high-value minerals or restricted goods);
• Has an ownership or transaction pattern that is unusually complex without an apparent legitimate commercial purpose;
• Has previously triggered a fraud, sanctions, or suspicious-activity flag on the Platform.

5. Sanctions & Watch-List Screening

We screen users and, where feasible, their beneficial owners and counterparties, against sanctions and watch lists maintained by the United Nations, the United States (including OFAC's Specially Designated Nationals list), the European Union, the United Kingdom, and other applicable authorities, at registration and on an ongoing basis. You must not register, transact, or attempt to transact if you, your business, or any beneficial owner is a sanctioned party, is located in a comprehensively sanctioned jurisdiction, or is acting on behalf of a sanctioned party, unless you hold a valid licence or authorisation permitting the activity and have disclosed it to us in advance.

6. Ongoing Transaction Monitoring

We monitor account activity and transactions on an ongoing basis for patterns consistent with money laundering, terrorist financing, sanctions evasion, or platform-circumvention (see our Terms & Conditions), using a combination of automated rules, AI-assisted classification, and human review. This includes monitoring in-platform messages for indicators of off-platform payment solicitation or undisclosed contact-sharing, and monitoring transaction size, frequency, and counterparty patterns for anomalies relative to your registered business profile.

We may request additional information or documentation about any transaction at any time, and may pause, freeze, or decline to process a transaction pending the outcome of that review.

7. Suspicious Activity Reporting

Where we identify activity we reasonably suspect is linked to money laundering, terrorist financing, sanctions evasion, or other financial crime, we will file a report with the competent financial intelligence unit or other authority as required by applicable law. Consistent with "tipping-off" prohibitions under AML law, we are not able to confirm to you whether a report has been filed in relation to your account.

8. Prohibited Customers & Activities

You may not use lockt, and we will decline or terminate your access, if:

• You cannot or will not complete the KYC verification described in Section 3;
• You, your business, or a beneficial owner appears on a sanctions or watch list, or is located in a comprehensively sanctioned jurisdiction, without a valid licence;
• You attempt to structure transactions to fall below a reporting or verification threshold;
• You attempt to use lockt to move funds unconnected to a genuine underlying trade in physical commodities;
• You solicit or agree to settle a lockt-introduced trade outside our escrow system to avoid verification, monitoring, or fees (see our Terms & Conditions, "No Circumvention of the Platform");
• You provide false information about the purpose, source, or destination of funds.

9. Recordkeeping

We retain KYC records, transaction records, screening results, and suspicious-activity assessments for at least five years from the end of your relationship with lockt or the relevant transaction, whichever is later, or for such longer period as required by applicable law, ongoing investigation, or litigation. Further detail on data retention is set out in our Privacy Policy.

10. Governance, Training & Compliance Officer

lockt maintains a designated compliance function responsible for this Policy, for escalation of suspicious-activity assessments, and for liaison with regulators and financial intelligence units. Personnel with access to KYC, transaction, or dispute data relevant to compliance receive periodic AML/CTF and sanctions training appropriate to their role.

11. Your Obligations as a Customer

• Provide accurate, complete information at registration and keep it up to date;
• Respond promptly and truthfully to any request for further information or documentation;
• Use the Service only for genuine trade in the commodities registered on your profile;
• Fund and receive escrow only through the Platform's designated payment channels, not through side payments intended to bypass escrow;
• Notify us promptly if you become aware that your account, or a transaction you are party to, may have been used for an unlawful purpose.

12. Consequences of Non-Compliance

Failure to comply with this Policy is a material breach of our Terms & Conditions and may result in, without limitation: rejection or suspension of your KYC application; freezing of pending escrow; refusal to release, or forced refund of, escrow funds; suspension or termination of your account; forfeiture of any fees already properly charged; and reporting to law enforcement, financial intelligence units, or sanctions authorities, where required by law.

13. Reporting a Concern

If you become aware of suspicious activity, an attempt to circumvent verification or escrow, or any other conduct that may violate this Policy, please report it to support@lockt.international as soon as possible. We treat such reports confidentially to the extent permitted by law.

14. Changes to This Policy

We may update this Policy to reflect changes in applicable law, regulatory guidance, or our risk assessment. We will post the updated Policy with a new effective date; material changes will be notified through the Platform where appropriate.

15. Contact Us

Questions about this Policy can be sent to:

• Email: support@lockt.international
• Phone: +254 701 017 333
• Registered office: lockt International Ltd., Accra, Ghana

See also our Terms & Conditions and Privacy Policy.